The opinion of the court was delivered by: Jeremy Fogel United States District Judge

STIPULATION AND [PROPOSED] ORDER TO STAY CIVIL FORFEITURE ACTION

IT IS HEREBY STIPULATED by and between plaintiff United States of America and claimants Terry and Rebecca Solomon, through undersigned counsel, that this action be stayed pursuant to 18 U.S.C. § 981(g). Claimants are currently awaiting trial in United States v. Solomon, et al., CR 06- 00818 JF. The allegations in the forfeiture complaint are based, in large part, on the allegations at issue in the pending criminal action. Consequently, the parties agree that a stay in the forfeiture proceeding is appropriate in order to preserve claimant's right against self-incrimination in the related criminal matter, as well as to not jeopardize the government's ability to prosecute the criminal action. The parties thus request that matter be stayed pending resolution of the related criminal matter and that any pending deadlines or assigned dates also be stayed and vacated until the resolution of the related criminal case. Upon the resolution of the criminal case, the parties will notify the Court so that the forfeiture matter may be set for further status. Alternatively, should the Court wish to set the matter for status at this time, the parties request that the matter be set for status in approximately months. Accordingly, the parties request that the Case Management Conference currently set for Friday, July 18, 2008, be vacate.

Upon the stipulation of counsel, and good cause appearing, the above-entitled civil forfeiture action is stayed in light of the pending related criminal prosecution of claimants Terry and Rebecca Solomon. The case management conference currently scheduled for July 18, 2008, is vacated. The matter is continued until __________ 1/23/09 for further status.

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